Associated enterprises: arm's-length adjustments reallocate profits and require coordinated tax adjustments between States.

Article 9 provides an arm's length adjustment mechanism for enterprises that are associated by participation in management, control or capital, or by common persons, permitting inclusion and taxation of profits that would have accrued absent non-arm's-length conditions; it preserves domestic tax determination rules subject to consistency with the Article and requires the first State to make appropriate adjustments, with competent authorities consulting as necessary.

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